STATE OF SOUTH CAROLINA )

)
COUNTY OF BEAUFORT )
)
JUNIOR SPORTS CORPORATION, INC.
)
Plaintiff(s) )
)
n. )
)
DAVID GOOLSBY and JUNIOR GOLF
)
ACADEMY OF HILTON HEAD, INC.
Defendant(s) )
(Please Print) SC Bar #:
Submitted By: Terry A. Finger, Esq.
Telephone #:
Address: Finger & Fraser, P.A.
Fa #:
2012
843-681-7000
843-681-8802
PO Box 24005
Other:
Hilton Head Island, SC 29925
E-mail: tfnger@fngerlaw.com
NOTE: The cover sheet and information contained herein neither replace nor supplements the ting and service of pleadings or other papers
as required by law. This form is required for the use of the Clerk of Court for the purpose of docketing. It must be flled out completely,
signed, and dated. A copy of this cover sheet must be sered on the defendant(s) along with the Summons and Complaint.
DOCKTING IFORATION (ckecka0tbataly)
*qActiaai 1edgmeat5ettlemeatdaaatcamplete
@ JURY TRIAL demanded in complaint. _ NON-JURY TRIAL demanded in complaint.
_ This case is subject to ARBITRATION pursuant to the Court Annexed Alterative Dispute Resolution Rules.
_ This case is subject to MEDIATION pursuant to the Court Annexed Alternative Dispute Resolution Rules.
_ This case is exempt fom ADR. (Proof of ADRxemption Attached)
NATUR OF ACTION (Check One Box Below)
Contracts Torts- Professional Malpractice
0 Constructions ( 1 00) 0 Dental Malpractice (200)
0 Debt Collection (110) 0
Legal Malpractice (21 0)
D Employment (120) D Medical Malpractice (220)
D General ( 130) Previous Notice of Intent Case#
Breach of Contract (140)
20_-CP-
D Other (199) 0
Notice/ File Med Mal (230)
0
Other (299)
Inmate Petitions Judgments/Settlements
D
PCR (500) D Death Settlement (700)
D Mandamus (520) 0
Foreign Judgment (71 0)
D Habeas Corpus (530) D Magistrate's Judgment (720)
D Other (599) 0 Minor Settlement (730)
D
Transcript Judgment (740)
Lis Pendens (750)
D
Transfer of Structured
Settlement Payment Rights
Application (760)
D
Other (799)
Special/Complex /Other
D Environmental (600) D Pharmaceuticals (630)
D Automobile Arb. (610)
D Unfair Trade Practices (640)
D Medical (620) D Out-of State Depositions (650)
0 Other (699) 0 Sexual Predator (510)
Torts-Personal Injury
0 Assault/Slander/Libel (300)
0
Conversion (31 0)
D Motor Vehicle Accident (320)
D
Premises Liability (330)
D Products Liability (340)
D Personal injury (350)
0 Other (399)
Administrative Law/elief
D Reinstate Driver's License (800)
D Judicial Review (81 0)
D Relief(820)
D Permanent Injunction (830)
D Forfeiture-Petition (840)
D
Forfeiture-Consent Order (850)
D
Other (899)
Real Property
0
Claim & Delivery (400)
0
Condemnation (410)

Foreclosure (420)
D Mechanic's Lien (430)
0
Partition ( 440)
0 Possession (450)
D Other (399)
Appeals
0
Arbitration (900)
0 Magistrate-Civil (910)
D Magistrate-Criminal (920)
D
Municipal (930)
D Probate Court (940)
0
SCDOT (950)
D Worker's Comp (960)
D Zoning Board (970)
D Administrative Law Judge (980)
0 Public Serice Commission (990)
0 Employment Security Comm (991)
0 Other (999)
f
Submitting Party Signature:
, ', -..
Date: October 1 , 2013
Note: Frivolous civil proceedings may be subject to sanctions pursuant to SCRCP, Rule 11, and the South Carolina Frivolous
Civil Proceedings Sanctions Act, S.C. Code Ann. 15-36-10 et. seq.
SCCA I 234 (07 /09) Page 1 of 2
jJ~
FOR MANDATED ADR COUNTIES ONLY
Allendale) Anderson, Beaufort, Colleton, Florence, Greenville,
Hampton, Horry, Jasper, Lexington, Pickens (Family Court Only), and Rchland
SUPREME COURT RULES REQUIRE THE SUBMISSION OF ALL CIVIL CASES TO AN ALTERNATIVE
DISPUTE RESOLUTION PROCESS, UNLESS OTHERWISE EXEMPT.
You are required to take the following action(s):
1. The parties shall select a neutral and fle a "Proof of ADR" form on or by the 210
1h
day of the fling of this
action. If the parties have not selected a neutral within 210 days, the Clerk of Court shall then appoint a
primary and secondary mediator from the current roster on rotating basis from among those mediators
agreeing to accept cases in the county in which the action has been filed.
2. The initial ADR conference must be held within 300 days afer the fling of the action.
3. Pre-suit medical malpractice mediations required by S.C. Code 15-79-125 shall be held not later than 120
days afer all defendants are served with the "Notice of Intent to File Suit" or as the court directs. (Medical
malpractice mediation is mandatory statewide.)
4. Cases are exempt from ADR only upon the following grounds:
a. Special proceeding, or actions seeking extraordinary relief such as mandamus, habeas corpus, or
prohibition;
b. Requests for temporary relief;
c. Appeals
d. Post Conviction relief matters;
e. Contempt of Court proceedings;
f. Forfeiture proceedings brought by govermental entities;
g. Mortgage foreclosures; and
h. Cases that have been previously subjected to an ADR conference, unless otherwise required by
Rule 3 or by statute.
5. In cases not subject to ADR, the Chief Judge for Administrative Purposes, upon the motion of the court or
of any party, may order a case to mediation.
6. Motion of a party to be exempt from payment of neutral fees due to indigency should be fled with the
Court within ten (I0) days afer the ADR conference has been concluded.
Please Note: You must comply with the Supreme Court Rules regarding ADR.
Failure to do so may affect your case or may result in sanctions.
SCCA I 234 (07 /09) Page 2 of 2
STATE OF SOUTH CAROLINA
COUNTY OF BEAUFORT
JUNIOR SPORTS CORPORATION,
INC.,
Plaintiff,
vs.
)
)
)
)
)
)
)
)
)
)
DAVID GOOLSBY and JUNIOR GOLF )
ACADEMY OF HILTON HEAD, INC.,
)
Defendants.
)
)

)
TO: THE DEFENDANTS ABOVE NAMED
YOU ARE HEREBY SUMMONED and required to answer the Complaint m this
action, a copy of which is herewith served upon you, and to serve a copy of your Answer to said
Complaint on the subscriber at his ofce located at 35 Hospital Center Common, Suite 200, Post
Ofce Box 24005, Hilton Head Island, South Carolina 29925-4005, within thirty (30) days afer
the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint
within the time aforesaid, the Plaintiff in this action will apply to the Court for a judgment by
default for the relief demanded in this Complaint.
YOU WILL ALSO TAKE NOTICE that the Plaintiff will move for an order of
reference or that the Court may issue a general order of reference of this action to a
master/special referee, pursuant to Rule 53, South Carolina Rules of Civil Procedure.
Hilton Head Island, South Carolina
October L, 2013

FINGER & FRASER, P.A.
4 Terry A. Fger
35 Hospital Center Common, Suite 200
Post Offce Box 24005
Hilton Head Island, SC 29925-4005
843-681-7000
Attorneys for Plaintif
STATE OF SOUTH CAROLINA
COUNTY OF BEAUFORT
JUNIOR SPORTS CORPORATION,
INC.,
Plaintiff,
vs.
)
)
)
)
)
)
)
)
)
l
DAVID GOOLSBY and JUNIOR GOLF
)
ACADEMY OF HILTON HEAD, INC.,
)
Defendants.
)
)
)
<?

IN THE COURT oMMOAS
FOURTEENTH JUDtQ CIRC
CIVIL ACTION NO.: _
L ' _7
',_r "'
COMPLAINT
(Jury Trial Demanded
)
\./,:.
'I
(
.
The Plaintiff, complaining of and against the Defendants herein, would respectflly show
unto this Honorable Court that:
1. The Plaintiff, Junior Sports Cororation, Inc. ("JSC"), is a cororation organized
and existing in the State of South Carolina with its principal place of business in the County of
Beaufort, State of South Carolina.
2. Upon information and belief, Defendant David Goolsby ("Goolsby") is a citizen
and resident of the Town of Hilton Head Island, County of Beaufort, State of South Carolina and
was previously an employee of JSC.
3. Upon information and belief, Defendant Junior Golf Academy of Hilton Head,
Inc. ("Golf Academy") is a corporation organized and existing in the State of South Carolina
with its principal place of business in the County ofBeaufort, State of South Carolina.
4. This Court has jurisdiction over this matter and venue is properly before this
honorable court.
FOR A FIRST CAUSE OF ACTION
(Violation of S.C. Trade Secrets: S.C. Code Ann. Sec. 39-8-20, et al. as to All Defendants
)
5. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
...
-1 IR
6. Upon information and belief, on or about June 13, 2013, Goolsby incorporated
Defendant Golf Academy with the S.C. Secretary of State.
7. Prior to April 2013, Defendant Goolsby was a employee of the Plaintiff on
Hilton Head Island in the position of "coach" for junior golfers regarding their swing, a well as
golf course management.
8. During Goolsby's tenure as an employee of the Plaintiff, Goolsby became
comprehensively acquainted with the program and system of the Plaintiff, along with personal
information regarding the students, their parents, the management and the faculty of !L.
9. Gooslby was informed of or should reasonably have known from the
circumstances of the existence of any of JSC's trade secrets.
10. Goolsby had a duty to refain fom using or disclosing the trade secret(s) without
JSC's permission, independently of, and in addition to any written contract of employment,
secrecy agreement, non-compete agreement or any other agreement between the employer,
namely JSC, and the employee, Goolsby.
1 1. As a direct and proximate result of the misappropriation, wrongful disclosure or
wrongful use of JSC's trade secrets, damages have accrued in an amount to be proven at a trial of
this matter.
12. For other relief enjoining the appropriation, disclosure, use or any other wrongfl
acts by Goolsby, individually or through Golf Academy pertaining to any trade secrets or any
other inforation which he received as a direct result of his prior employment with JSC.
FOR A SECOND CAUSE OF ACTION
(Interference with Contractual Relationship as to All Defendants)
13. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
14. JSC has contractual relationships through written contracts with the parents of the
students to whom it provides golf instruction services.
2
Il . , !ll_ -
15. Goolsby and Golf Academy each have knowledge that those contracts exists,
under what circumstances the contracts were procured and the terms set forth in that contractual
relationship.
16. Upon information and belief, Goolsby and Golf Academy have, independently
and concurrently contacted the parents of present students in order to attempt to procure a breach
of the contracts with the JSC in favor of obtaining a contract with Golf Academy.
17. There is no justifcation for the procurement of the breach of the aforementioned
contracts.
18. During the procurement of the breaches on several of the contracts, Goolsby
and/or Golf Academy made numerous false and defamatory statements regarding JSC which will
be fther set forth in the discovery phase of this matter.
19. As a direct and proximate result of the tortious interference with the contractual
relations that JSC had with the parents of its students, JSC has been damaged in an amount to be
proven at a trial of this matter.
FOR A THIRD CAUSE OF ACTION
(Violation of S.C. Unfair Trade Practices Act as to All Defendants)
20. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
21. As a result of Goolsby and Golf Academy's practices, set forth hereinabove, JSC
has suffered an ascertainable loss of money as a result of the use and/or employment by the
Defendants of an unfair and deceptive method or practice, namely:
A. By contacting parents of current students at JSC and spreading falsehoods
regarding the company regarding the ability of the Plaintiffs golf
instruction program to produce any results;
B. By falsely advertising to current students of the Plaintiff that Golf
Academy was able to offer online classes for international students; and
3
. .
C. By stealing the list of names and contact information from the Plaintiff
and using that information to target and attempt to poach current students
of the Plaintiff.
All of the allegations hereinabove are capable of repetition and impact the public
interest in the State of South Carolina.
22. As a direct and proximate cause of the violation of the S.C. Unfair Trade Practices
Act as set forth hereinabove, JSC has been damaged in an amount to be proven at a jury trial of
this matter, costs of pursuing this action, attoreys' fees and treble damages.
FOR A FOURTH CAUSE OF ACTION
(Defamation as to Goolsby
)
23. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
24. Goolsby attempted to impeach the honesty, integrity and/or reputation of JSC by
stating that JSC's methodology for golf instruction was and is poor and that any student of JSC
will not gain any beneft by obtaining instruction at JSC.
25. Such false information was published and/or disseminated with actual or implied
malice by Goolsby which directly concerned JSC.
26. As a direct and proximate result of the defamatory statements, JSC has been
damaged in an amount to be proven at a trial of this matter.
FOR A FIFTH CAUSE OF ACTION
(Conversion as to Goolsby
)
27. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
28. Goolsby appropriated the personal property of JSC on or immediately prior to
leaving hs employment in the form of contact lists for current students and their parents of JSC.
4
I
29. JSC had an interest in all property belonging to the company to the exclusion of
all other persons.
30. Upon information and belief, Goolsby converted the property belonging to JSC
for his own use and wholly without JSC's permission or knowledge.
3 1. As a direct and proximate result of Goolsby's actions, JSC has been damaged in
an amount to be proven at a trial of this matter.
FOR A SIXTH CAUSE OF ACTION
(Civil Conspiracy as to all Defendants)
32. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
33. Goolsby and Golf Academy conspired and colluded together to negatively impact
the fnances and/or damage the business of JSC which occurred via the actions set forth in the
allegations set forth above.
34. As a direct and proximate result of the conspiracy, JSC has been damaged in an
amount to be proven at a trial of this matter.
FOR A SEVENTH CAUSE OF ACTION
(Temporary and Permanent Injunction as to All Defendants)
35. Each and every allegation set forth in the preceding paragraphs are hereby
realleged and reiterated as if set forth verbatim herein.
36. An injunction regarding the actions of the Defendats as to utilizing information
taken from the Plaintiff and regarding spreading falsehoods about the Plaintiff is necessay for
the protection of the legitimate interests of the Plaintiff.
37. Such an iftiunction against the Defendants regarding the actions set forth
hereinabove is not unduly harsh or oppressive in curtailing the legitimate eforts of the
Defendat(s) to ear a livelihood.
5
38. There is no adequate remedy at law which will compensate the Plaintiff lor the
continuation of the Defendants' actions.
WHEREFORE, Plaintiff prays this Court for judgment against the Defendants for
actual, consequential and punitive damages in an appropriate amount, for the costs of this action,
treble damages where allowed by statute, for a permanent and preliminary injunction against
Golf Academy and for other and frther relief as this Honorable Court deems just and proper.
Hilton Head Island, South Carolina
October., 2013

6
FINGER & FRSER, P.A.
Terry A. F' ger
35 Hospital Center Common, Suite 200
Post Ofce Box 24005
Hilton Head Island, SC 29925-4005
843-681-7000
Attorneys for Plaintif
FINGER & FRASER, P.A.
TERRY A. FINGER
DENSON H. FRASER, JR.
ANNE C. MARSCHER D
TYLER A. MELNICK
JULIE A SERAFINO
MICHAEL C. CERRATJ,
Of Counsel:
ARTHUR F. ANDREWSt
Clerk of Court - Civil Filing
Beaufort County Courthouse
1 02 Ribaut Road
Beaufort, SC 29901
ATTORNEYS AT LAW
35 Hospital Center Common, Suite 200 (29926)
Post Ofce Box 24005
Hilton Head Island, South Carolina 29925
(843) 681-8802 Facsimile
(843) 681-7000 Telephone
tfnger@fngerla w .com
October 7, 2013
Also admitted in:
Georgia
Pennsylvania
Califoria
t New York
O Court Certified Mediator
Court Certifed Arbitrator f Mediator
Re: Junior Spors Corporation, Inc. v Goolsby andolf Academy ofHilton Head
Beaufort County Civil Case No. 13CP-07-0 f
Our File No. 1135.022
Dea Civil Filing Clerk:
Enclosed for fling please fi nd original and one copy of our Civil Coversheet, Summons,
and Complaint.
Please fle these documents and retur the clocked copies in the envelope provided.
Also enclosed is our filing fee of$150.00.
Thank you for your assistance.
With kind regards, I a
Sincerely,
FINGER & FRASER, P .A.

Veronica Hagopian
Paralegal to Mr. Finger